Continuing education (CE) gets complicated fast when you’re licensed in more than one state. The NAIC Continuing Education Reciprocity (CER) Agreement exists to reduce that friction by encouraging participating jurisdictions to accept CE course approvals on a reciprocal basis—so a provider doesn’t have to repeat the same approval work in every non-resident state.
The NAIC originally adopted the CER Agreement in 2004 and later refreshed it in 2019 through the NAIC Uniform Education (D) Working Group. The updated 2019 CER Agreement outlines a home-state substantive review process (five steps) and reflects modern delivery and filing realities like electronic submission and online CE platforms. As of August 24, 2022, the NAIC page indicates that 46 states/jurisdictions had signed the refreshed agreement, while a short list is identified as not participating.
For TSI National learners and the teams that support them, reciprocity isn’t an abstract policy topic. It changes the operational question you have to answer every renewal cycle: “Will this CE course be accepted where I’m licensed, and how do we confirm that quickly?”
1) What the NAIC CER Agreement changes (and what it doesn’t)
What changes: The CER framework is intended to streamline multi-jurisdiction CE course approval. Under the reciprocal process, a CE provider’s home state performs a substantive review of a course, which can reduce or eliminate duplicative review by non-resident states that participate. In practice, that can mean fewer separate filings, less waiting, and clearer scaling for multi-state CE offerings.
What doesn’t change: Reciprocity is about course approval processes across jurisdictions—not a promise that every course is automatically accepted everywhere, or that state-specific CE rules disappear. Producers and compliance teams still need a verification habit: confirm that the course is approved/accepted for the licensee’s state(s) and that completion is properly recorded.
2) Training implications for licensing prep and CE compliance
Even though CER is a CE-course approval framework, it has direct downstream impact on licensing and compliance operations:
- Cleaner CE planning for multi-state producers: When providers can more efficiently gain multi-jurisdiction approval, learners have a better chance of finding a single course (or bundle) that works across multiple licenses—reducing last-minute scrambling.
- More consistent course catalogs for onboarding: Agencies onboarding new producers can standardize CE options sooner, rather than maintaining a patchwork of state-by-state exceptions.
- Better alignment with online delivery: The 2019 CER Agreement includes appendices acknowledging electronic submission and online delivery platforms—important for teams using self-study and virtual learning to keep CE completion predictable.
At TSI National, the operational takeaway is simple: build your CE workflow around verification + standardization. Reciprocity can reduce administrative friction, but your compliance outcomes still depend on choosing the right courses for the right states and tracking completion.
3) What CE students and licensed producers should do this week
If you’re the one taking CE (especially with more than one state license), use this short execution checklist:
- List every jurisdiction you need to renew. Don’t rely on memory—write it down and keep it with your CE plan.
- Check whether each jurisdiction is participating in the NAIC 2019 CER Agreement. The NAIC page lists participating and non-participating jurisdictions and explains that active participation requires a signed agreement and may require implementation steps (including notifying providers of a reciprocity filing start date).
- Before you enroll, confirm course acceptance for your state(s). Reciprocity aims to reduce duplicative approvals, but your job is to confirm that the course you select is approved/accepted where you hold licenses.
- Plan CE backward from your renewal deadline. Set internal checkpoints (for example: “course selected,” “course completed,” “completion recorded”) so you’re not troubleshooting transcript posting at the last minute.
- Keep completion records organized. Save completion certificates and course details in one place, especially if you’re managing multiple states or changing agencies.
If you’re also studying for initial licensing: treat CE reciprocity as an early professional habit. The same discipline you use for exam prep—structured plan, verification, and tracking—becomes your compliance advantage after you’re licensed.
4) What managers and compliance leads should implement (controls, cadence, and escalation)
Reciprocity only helps if your team’s process prevents the most common failure mode: someone completes CE that doesn’t count in one of their jurisdictions. Build controls that catch issues before a producer spends time (and money) on the wrong course.
Manager quick-start (implement in one week):
- Build a “CE footprint” roster. Maintain a simple list of each producer’s resident state and all non-resident jurisdictions. Use it as the starting point for every CE assignment, not an afterthought.
- Maintain a reciprocity participation reference and flag exceptions. Use the NAIC CER page to keep a current list of participating vs. non-participating jurisdictions. Treat non-participating jurisdictions as “manual handling required” in your workflow.
- Standardize an approved CE catalog by footprint. Create a short list of approved course options for your most common state combinations. Fewer options reduces enrollment errors and makes completion tracking easier.
- Require pre-enrollment verification evidence. Add one required field in your LMS, spreadsheet, or ticketing tool: “Course approval/acceptance confirmed for: [states].” This can be a screenshot, provider approval list, or state lookup reference—whatever your team uses consistently.
Ongoing cadence (keeps renewals from becoming emergencies):
- Run a 90/60/30-day renewal cadence with escalation rules. At each checkpoint, verify: (1) enrollment, (2) progress, (3) completion, and (4) posting/recording status. Escalate immediately when a producer has a multi-state footprint that includes a non-participating jurisdiction or when a state’s implementation timing is unclear.
- Use reciprocity to reduce duplication—but don’t relax supervision. If a course is intended to be used across multiple jurisdictions, treat the “counts in all required states” check as a required control, not a best-effort step.
- If you sponsor or develop CE, align internal readiness to the home-state review model. The 2019 CER Agreement describes five steps for a home state’s substantive review and acknowledges electronic submission and online delivery. Operationally, that means your team should maintain tight version control, consistent learning objectives, and delivery-platform documentation so filings don’t stall.
This is the same philosophy TSI National applies to training outcomes: reduce confusion with a structured path, then track execution so compliance doesn’t rely on last-minute heroics.
5) Where reciprocity still creates friction (and how to plan for it)
The NAIC page explicitly lists several jurisdictions as not participating: American Samoa, Florida, Guam, Northern Mariana Island, and Virgin Island. If you (or your producers) hold licenses in any non-participating jurisdiction, plan for additional review/acceptance steps and avoid assuming a course approved elsewhere will transfer cleanly.
Also note the NAIC’s point on what “active participation” entails: a Commissioner must sign the NAIC 2019 CER Agreement, and a state may need policy/form changes and must inform providers of the reciprocity filing start date. Operationally, that means participation status is a necessary signal—but your workflow still needs state-by-state confirmation at the course level.
CTA: If you’re building a repeatable CE completion plan for yourself or your agency, use TSI National’s licensing prep and continuing education resources at https://www.tsinational.com/.
Source: Original article
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